What the Board Should Be Asking About the Compliance Program
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
False Claims Act Insights - The Art and Science of Corporate Compliance in Managing FCA Risk
An Ounce of Prevention: Keys to Understanding and Preventing AI and Cybersecurity Risks
Behavioral Health Compliance
The Justice Insiders Podcast: Using External Resources for Internal Investigations
Bank Investigations and Enforcement Actions: Lessons Learned — The Consumer Finance Podcast
The Justice Insiders Podcast: SEC Plays Chicken with Jarkesy
What Nonprofit Board Leadership Needs To Know About Internal Investigations
Compliance Series Part 3: Ensuring Compliance Programs are Effective
Compliance Programs Part 2: Designing a Successful Compliance Program
Compliance Programs Part 1: What is a Compliance Program and Why do Businesses Need One?
How to Combat Corporate Theft: Office Space - Hiring to Firing Podcast
All Things Investigations: Episode 28 - New French Anti-Corruption Investigative Guidance with Anne Gaustad and Bryan Sillaman
Investigative Power: Utilizing Self Service Solutions for Internal Investigations?
Internal Investigations and the Food, Beverage and Agribusiness Industry
CyberSide Chats: Cyber Law, Cybersecurity, and Whistleblowers. A Conversation with Ben Wright
Internal Investigations for Nonprofits: A Means of Identifying and Addressing Misconduct Before the Regulators Come Calling
Nuts and Bolts of a Repayment Investigation: Keys to Conducting Investigations Under the 60-Day Repayment Rule
Internal Investigations in the Asia-Pacific Region
Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more
A recent court decision serves as an important reminder that attorney-client privilege may not apply to communications between an executive and a company’s counsel during the course of an investigation unless individual...more
In our continuing quest to improve how companies manage risk, it’s inevitable we’d eventually discuss the “Three Lines of Defense,” a risk management model for clarifying roles and responsibilities. It explains the...more
In 2019, the Criminal Division of the U.S. Department of Justice (DOJ) continued its efforts, begun a few years prior, to enhance transparency with respect to the DOJ's prosecutorial decision-making. In public statements, DOJ...more
The MLB Commissioner held senior leadership accountable for illegal sign stealing - even though the conduct generally involved players and low-level operations employees. On January 13, 2020, Major League Baseball (MLB)...more
The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...more
After 35 years of dealing with civil, regulatory, and federal criminal investigations (both as a federal prosecutor and as a civil and criminal defense attorney), I realized understanding the judicial process and mapping out...more
In a November 29, 2018 speech, Deputy Attorney General Rod Rosenstein announced a softening of the US Department of Justice’s (DOJ) policy on giving credit for cooperation in corporate prosecutions. As memorialized in the...more
On November 29, 2018, Deputy Attorney General Rod Rosenstein announced changes to the Department of Justice’s policy concerning individual accountability in corporate cases, stating that “pursuing individuals responsible for...more
By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more
I respect prosecutors, most of them at least. I had the fortunate opportunity to work with a number of terrific prosecutors. Most are intelligent, hard working and committed to doing the right thing. I recognize that there...more
The Business Law Section’s Director and Officer Liability Committee conducted a program at the Section’s Spring Meeting in Montréal. The program focused on the recent Yates memorandum of the U.S. Department of Justice (DOJ),...more
Companies face an ever-changing constellation of risks, enforcement priorities and demands for internal controls and compliance program elements. As more resources are poured into government enforcement programs, companies...more
As we continue to operate under the Yates Memorandum, a number of interesting and difficult issues are sure to develop surrounding internal investigations and individual culpability. Corporate internal investigations have to...more
On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more
On April 5, 2016, the Department of Justice’s (“DOJ”) Fraud Section Chief, Andrew Weissmann, issued a memo (the “Weissmann Memorandum”) announcing a one-year Pilot Program that offers a carrot and stick approach to...more
This week, the Fraud Section of the Department of Justice (DOJ) announced a pilot program that extends additional “mitigation credit” to qualifying companies that “fully cooperate” in matters involving the Foreign Corrupt...more
Welcome to the third issue of Focus on China Compliance for 2015. According to the FCPA Blog’s October 2015 Corporate Investigations List, China leads the countries reported to be involved in FCPA investigations with 29...more
On October 22, 2015, the U.S. Department of Justice Principal Deputy Assistant Attorney General Benjamin C. Mizer, who oversees DOJ’s Civil Division, spoke at the 16th Pharmaceutical Compliance Congress and Best Practices...more
On September 9, 2015, United States Deputy Attorney General Sally Yates released a memorandum titled “Individual Accountability for Corporate Wrongdoing,” the latest in a series of corporate prosecution guidelines written by...more
The United States Department of Justice (DOJ) recently issued a memorandum to various enforcement agencies. The memorandum, available here, focuses on holding individuals accountable for corporate fraud and misconduct. The...more
Earlier this month, we discussed a memorandum issued by Deputy Attorney General Sally Quillian Yates of the U.S. Department of Justice (DOJ). This memorandum, referred to as the “Yates Memo,” reaffirms the Government’s...more
While naysayers believe the Department Of Justice's (DOJ’s) memo is going to result in major complications and headaches for companies experiencing government investigations, ethical companies are unlikely to be affected much...more
On September 22, 2015, the U.S. Department of Justice’s Assistant Attorney General in charge of the Criminal Division, Leslie R. Caldwell, spoke at the Global Investigations Review Conference in New York, addressing the...more
Responding to criticism stemming from a lack of individual prosecutions as a result of the financial crisis, Deputy Attorney General Sally Yates has issued a new guidance memorandum establishing six new steps for federal...more